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VINCENT L. COSTA,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. '.7 'I .) I. J C.-, "l 'II', ...-,
CIVIL ACTION - LAW
THERESA A. COSTA,
IN DIVORCE
Defendant
COMPI....INT
AND NOW COMES Plaintiff, VINCENT L. COSTA, by his Attorney,
Kenneth A. Wise, Esquirll, and respectfully represents as follows:
1. Plaintiff, Vinoent L. Costa, is an adult individual
residing at 516 lIummel Avenue, Lemoyne, Cumberland County,
Pennoylvania 17043.
2. Defendant, 'I'heresa A. Costa, is an adult individual
residing at 1 Richland Lane, Apartment 207, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. Both Plaintiff and Defendant have been bonaflde residents
in the Commonwealth and County of Cumberland for at least 6 months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 6, 1997,
in Monroe County, Pennsylvania.
5. Defendant is not in the military service.
6. There have been no prior aotions for divorce or annulment
of marriage between the parties in this or any other jurisdiction.
7. Plaintiff avers that the grounds upon which this aotion is
based is that the marr.iage is irretrievably broken.
Further,
Plaintiff avers that Defendant has offered such indignities to the